Overview

• The bench applied Manoj v State of MP (2023), mandating courts to weigh mitigating circumstances thoroughly before confirming a death sentence
• In Byluru Thippaiah’s case, probation and prison reports detailed his lack of prior offenses, good conduct, suicide attempts and reform potential—factors the Karnataka High Court had underexamined
• In Jai Prakash’s case, the court upheld his conviction based on body recovery, last-seen theory and DNA evidence while citing his impoverished background and satisfactory jail behavior as grounds against execution
• Both convicts were ordered to spend their natural lives behind bars without remission, signaling a shift in the application of the ‘rarest of rare’ standard
• The Supreme Court emphasized that crime brutality alone cannot meet the ‘rarest of rare’ threshold and lower courts must evaluate both aggravating and mitigating factors before imposing capital punishment